United States
 Environmental Protection
 Agency
 Municipal Environmental Research
 Laboratory
 Cincinnati OH 45268
 Research and Development
EPA-600/S2-81-239  Jan. 1982
 Project  Summary
Guide  for  Spill  Prevention
Control and Countermeasure
Inspectors

Walter Unterberg and Robert M.  Moorehead
  This  report is intended for use in
 training  and guiding  inspectors
 performing  compliance  inspections
 and  amendment inspections and in
 documenting these inspections to
 implement the Oil Pollution Preven-
 tion Regulations  promulgated in
 40CFR112 for  nontransportation-
 related onshore and offshore facilities.
  The  report  covers  the  Spill
 Prevention  Control and  Counter-
 measure (SPCC) regulations, the role
 of the SPCC inspector, the affected
 facilities, and procedures for carrying
 out the inspection. It contains forms
 for use by the inspector in the field and
 for documentation.
  The use of these forms will provide
 nationwide  uniformity  in  SPCC
 reporting.  Suggested procedures
 appear below in short form, applicable
 to all inspections:

     The SPCC Inspector's 1-2-3

  1.  In field, fill out "SPCC Inspection
     Field Sheet" (1 page) (EPA Form
     7500-53)

  2.  If facility in compliance
     Fill out "APCC Inspection Sum-
     mary Sheet" (1 page) only (EPA
     For 7500-52)

     // facility NOT in compliance
     Fill out  "SPCC  Inspection
     Summary Sheet" (1 page) (EPA
     Form  7500-52) and "Detailed
     SPCC Documentation"  (7
     pages) (EPA Form 7500-54)

 ,3.  Enter information in EPA-SPCC
     Data Bank;

     Form A - Facility Indentification
     Form E -  Inspection/Enforce-
     ment Report
     Form S - Spill Report (if required)

  This Project Summary was devel-
 oped by EPA 's Municipal Environmen-
 tal Research Laboratory, Cincinnati.
 OH, to announce key findings of the
 research project that  is  fully docu-
 mented in a separate report of the
 same title (see Project Report order-
 ing information at back).

 Introduction
  In  December  1973,  the  U.S.
 Environmental Protection Agency (EPA)
 issued in the Federal Register its Oil
 Pollution  Prevention Regulations for
 Nontransportation-Related Onshore
 and Offshore Facilities (40CFR112). The
 purpose of these  regulations is  to
 prevent spills from nontransportation-
 related facilities  by  establishing
 procedures, methods, and equipment
 requirements for owners or operators of
facilities engaged in drilling, producing,
gathering, storing, processing, refining,
transferring, distributing, or consuming
oil.  These  regulations  require  the
owners  or operators of  designated
onshore and  offshore facilities  to

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prepare a Spill Prevention Control and
Countermeasure Plan (SPCC Plan) in
accordance  with  certain  guidelines
contained within the regulations. These
guidelines require  the installation  or
construction of certain spill prevention
systems depending upon the type of
operation conducted at the facility. The
intention of these  regulations  is that
these  spill  prevention  systems   be
designed,   installed,  and   operated
according  to   good engineering
practices.
  Associated with 40CFR112 are sev-
eral other environmental regulations:

  •  40CFR109,  Criteria  for  State,
     Local, and Regional Oil Removal
     Contingency Plans —  governing
     contingency plans that are part of
     SPCC plans under certain circum-
     stances when conventional spill
     prevention is not feasible;

  •  40CFR110, Discharge of Oil  —
     applying 'to the discharge of  oil
     into  navigable waters, adjoining
     shorelilnes, or waters of the con-
     tiguous zone;

  •  40CFR114, Civil Penalties for Vio-
     lation of Oil Pollution/Prevention
     Regulations — outlining enforce-
     ment procedures, with maximum
     liability of $5000 for each day a
     violation continues.

  The SPCC inspection program is the
mechanism  that  the  EPA  uses  to
determine   compliance  with   SPCC
regulations. Compliance inspections
enforce 40CFR112.3 by verifying that
an SPCC plan exists for a facility falling
under  40CFR112, that this  plan is
technically  adequate,  and  that  the
provisions  of  the  SPCC  plan have
actually been carried out in the  facility.
The  legal  basis  for  compliance
inspections   is  contained   in
40CFR112.3(b), which states, in part:

    "Owners or operators  of a
    facility for which an SPCC plan
    is required  ... shall maintain a
    complete copy of the plan . . .
    and shall  make such  plan
    available   to  the  Regional
    Administrator  for  on-site
    review during normal working
    hours."

  When a spill  of a certain  magnitude
has occurred from a facility having an
SPCC  plan, 40CFR112.4 requires the
owner or operator to submit his SPCC
plan to the EPA Regional Administrator
for  review  and possible  amendment.
The Regional Administrator may require
that the plan be amended to minimize
the possibilities of  spill recurrence.
After  EPA   review  of  the plan, an
amendment  inspection  may be
performed; this may result in additional
SPCC requirements being specified by
the EPA. The  legal  basis for  this is
contained  in  40CFR112.4(d),  which
states, in part:

    "After  review of  the  SPCC
    plan ... submitted by the owner
    or operator .  . .  the  Regional
    Administrator may require the
    owner or operator.. .to amend
    the  SPCC  Plan if he finds that
    the  Plan does not meet  the
    requirements of this part or
    that the amendment of the plan
    is necessary to prevent and to
    contain discharges  of oil from
    such a facility .  . . and shall
    specify  the  terms  of such
    amendment."

  EPA's SPCC regulations were to be
implemented by 11 January 1975 by
about 30,000  oil  marketing terminals
and bulk plants; about 285 oil refineries;
several  thousand production facilities,
both onshore and offshore; and many
bulk oil  consumers. As of June 1976,
the  EPA  had  completed  12,313
compliance  inspections. Evaluation of
the SPCC program to date, in terms of
spill histories  and  enforcement,  has
disclosed variations  among the EPA
regions.


Objective
  Uniformity in  carrying out  SPCC
inspections is desirable, and therefore,
a  document  that  provides  uniform
guidance on  a  nationwide  basis is
required. Also, personnel new to the
SPCC program need to be trained in
inspection   and  documentation
procedures.
  This  "Guide  for  Spill Prevention
Control  Countermeasure Inspectors" is
to be a training and guidance report for
those  performing  compliance
inspections  and  amendment
inspections and for documenting such
inspections to  enforce the Oil Pollution
Prevention  Regulations  promulgated in
40CFR112 for  nontransportation-
related  onshore and offshore facilities.
Operators/owners of  such  facilities
should also find this  report useful in
developing their SPCC plans.

Contents
  This report is divided into sections.
Section 1  is the introduction. Section 2
describes the role of the SPCC inspec-
tor, including the knowledge and skills
he  should possess, the  attitude and
behavior he should exhibit when deal-
ing with facility personnel, and the attire
and equipment he should take into the
field. Section 3 briefly covers the af-
fected nontransportation-related facili-
ties and their potential for incurring oil
spills. Section 4 is devoted to compliance
inspections — starting with  prepara-
tions for the inspection, then cpntinuing
with the initial contact with the facility
and the SPCC plan review, and ending
with the facility inspection  itself. Sec-
tion  5 deals with amendment inspec-
tions and parallels 4 in its sections. Sec-
tion  6 deals with  documentation of
inspections. This is followed by a sec-
tion on references.
  The appendices include texts of the
applicable federal  EPA SPCC regula-
tions (Appendix A), a discussion of
nontransportation-related  facilities
(Appendix B), an SPCC inspection check-  .
list (Appendix C), Report of SPCC In-  \
spection forms (Appendix D), and EPA-
SPCC  Data Bank forms (Appendix E).
The report concludes with a Glossary of
the most commonly used terms.
  The report is in looseleaf form so that
future additions, deletions, and correc-
tions can  easily be  made. Also, it per-
mits the report holder to insert  other
pages as desired.
  The full report was submitted in par-
tial fulfillment of Contract No. 68-03-
2648 by Rockwell  International,  New-
buryPark, California, under the sponsor-
ship  of  the  U.S. Environmental
Protection Agency.

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 W. Unterberg and R. M. Moorehead are with Rockwell International, Environ-
   mental Monitoring & Services Center, Newbury Park, CA 91320.
 John S. Farlow is the EPA Project Officer (see below).
 The complete report, entitled "Guide for Spill Prevention Control and Counter-
   measure Inspectors," (Order No. PB 82-115 296; Cost: $12.00,  subject to
   change) will be available only from:
         National Technical Information Service
         5285 Port Royal Road
         Springfield, VA 22161
         Telephone: 703-487-4650
 The EPA Project Officer can be contacted at:
         Oil and Hazardous Materials Spills Branch
         Municipal Environmental Research Laboratory—Cincinnati
         U.S. Environmental Protection Agency
         Edison, NJ 08837
U S GOVERNMENT PRINTING OFFICE, 1982 —559-017/7437

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United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Postage and
Fees Paid
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Protection
Agency
EPA 335
Official Business
Penalty for Private Use $300

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